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Comment for Federal Advisory Committees and Subcommittees 85 FR 21840

  • From: David Clarke
    Organization(s):
    Climate Safe Lending and Positive Money

    Comment No: 62476
    Date: 5/14/2020

    Comment Text:

    (2) the need for mandatory disclosure of material climate risks and opportunities

    Without comprehensive disclosure it is difficult for investors to assess their exposure to climate risks. A recent global report on the uptake of disclosures under the Taskforce for Climate Related Financial Disclosures (TCFD) showed that the average number of recommended disclosures per company is just a third of the 11 the TCFD recommends, while nearly a quarter of large companies have made no TCFD-aligned disclosures whatsoever. If the current rate of progress continues, the number of disclosures per company won’t reach the necessary level until 2028, which is far too late.